Privacy Policy

Global Privacy & Data Protection Policy

Last updated: 8 September 2026

Applies to the Airpay group of companies in India, the United Arab Emirates, Tanzania and Zambia.

About Airpay Group

“Airpay”, “Airpay Group”, “we”, “our” or “us” refers collectively to Airpay Payment Services Private Limited (“APSPL”) and its subsidiaries, affiliates, associate companies, branches and controlled entities operating in India, the United Arab Emirates (“UAE”), Tanzania, Zambia and other jurisdictions where the Airpay Group provides services.

Airpay Group provides payment processing, payment aggregation, merchant acquiring, financial-technology solutions, cross-border payment services, fraud-prevention solutions and related technology services. This Privacy Policy explains how we collect, use, store, share and protect your personal data, and the rights available to you under the data-protection laws of the jurisdictions in which we operate.

Where a specific Airpay Group entity determines the purposes and means of processing your personal data, that entity is the data controller / data fiduciary responsible for your data in its jurisdiction.

Who Is Covered by This Policy

This Policy applies to all persons whose personal data we process in connection with our websites, portals, APIs, mobile applications and services, including but not limited to:

  • Website and application visitors and registered users;
  • Merchants and their authorised representatives;
  • Customers who transact with our Merchants using Airpay’s services;
  • Prospective clients, vendors, suppliers and business partners; and
  • Employees and contractors, where applicable.
Legal Framework

Airpay Group processes personal data in accordance with the applicable data-protection, cybersecurity, payment-system, anti-money-laundering / counter-terrorist-financing (AML/CFT) and consumer-protection laws of each jurisdiction in which it operates, including in particular:

  • India – the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Information Technology Act, 2000 (and rules thereunder), together with applicable Reserve Bank of India directions.
  • UAE – Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”) and its implementing regulations; and, where Airpay operates within a financial free zone, the DIFC Data Protection Law No. 5 of 2020 or the ADGM Data Protection Regulations 2021, as applicable.
  • Tanzania – the Personal Data Protection Act, 2022 (Act No. 11 of 2022) and the Personal Data Protection (Personal Data Collection and Processing) Regulations, 2023, overseen by the Personal Data Protection Commission (PDPC).
  • Zambia – the Data Protection Act No. 3 of 2021, overseen by the Office of the Data Protection Commissioner.
Key Definitions

Airpay Group processes personal data in accordance with the applicable data-protection, cybersecurity, payment-system, anti-money-laundering / counter-terrorist-financing (AML/CFT) and consumer-protection laws of each jurisdiction in which it operates, including in particular:

  • Personal Data – any data about an individual who is identifiable by or in relation to such data.
  • Processing – any operation performed on personal data, including collection, recording, organisation, storage, use, disclosure, transfer or erasure.
  • Data Principal / Data Subject – the individual to whom the personal data relates (“Data Principal” under the DPDP Act; “Data Subject” under the UAE PDPL, the Tanzania PDPA and the Zambia Data Protection Act).
  • Data Fiduciary / Data Controller – the Airpay Group entity that determines the purpose and means of processing (“Data Fiduciary” under the DPDP Act; “Controller” under the UAE, Tanzania and Zambia laws).
  • Data Processor – a person who processes personal data on behalf of a controller/fiduciary.
Consent Management

By using Airpay’s websites and services, and, where required by law, by providing your consent through our consent or cookie mechanisms, you consent to the collection and processing of your personal data as described in this Policy. Consent is sought through clear and specific notices. You may withdraw or manage your consent at any time by contacting us at dpo@airpay.in. Withdrawing consent will not affect the lawfulness of processing carried out before withdrawal and may limit our ability to provide certain services. Where we rely on a legal basis other than consent (such as legal obligation, contract, or legitimate interest permitted by law), we will process your data on that basis.

Information We Collect

Depending on your relationship with us, we may collect the following categories of personal data:

  • Identity information – name, date of birth, nationality, gender, government-issued identifiers (such as passport number and, for Indian users, PAN), and details of nominees.
  • Contact information – e-mail address, mobile and telephone numbers, and postal address.
  • Financial information – bank account and payment-instrument details, settlement information, income details and transaction information.
  • Technical information – IP address, device identifiers, browser information, login records, and usage and interaction data.
  • Compliance information – KYC documentation, customer due-diligence and sanctions-screening records, and fraud-risk indicators.
  • Demographic and preference information – preferences and interests, used to tailor our services where lawful.

By providing your e-mail address, telephone numbers and other contact information, you agree that Airpay may contact you through one or more modes of communication in connection with the services and this Policy.

Purposes of Processing

We process personal data for the following purposes, among others:

  • Service delivery – account creation, merchant onboarding, payment processing, settlements and reconciliations, and administering your account.
  • Regulatory compliance – KYC verification, AML/CFT compliance, fraud prevention, tax and regulatory reporting, and record-keeping. As part of mandatory customer due diligence, Airpay may retrieve, verify and periodically review KYC documents (including, in India, from the Central KYC Records Registry (CKYCR)) and, where required, share information with regulators, governmental bodies, law-enforcement agencies and financial-intelligence units (including the Financial Intelligence Unit-India (FIU-IND)).
  • Customer support – complaint and grievance resolution, technical assistance and communications management.
  • Business improvement – analytics, product development and service enhancement.
  • Security and fraud prevention – risk monitoring, threat detection and cybersecurity controls.
  • Marketing – sending, where permitted, information about products, offers and market research; you may opt out at any time.
Legal Bases for Processing

We rely on one or more of the following legal bases, as permitted in each jurisdiction: your consent; performance of a contract with you; compliance with a legal or regulatory obligation; protection of vital interests; and legitimate interests (such as fraud prevention, network and information security, and improving our services) that are not overridden by your rights. Where the DPDP Act applies, we rely on your consent or on “certain legitimate uses” recognised under that Act.

Fraud Prevention and Risk Monitoring

As a regulated payments organisation, Airpay Group continuously monitors accounts and transactions to detect fraud, prevent financial crime, identify suspicious transactions, meet AML/CFT obligations, and protect customers and merchants. Airpay may suspend, refuse, delay, hold, reverse or review transactions, and may suspend accounts, where operational, legal, security or regulatory concerns are identified, in accordance with applicable law.

How We Share and Disclose Personal Data

Access to personal data is granted only to authorised employees, Airpay Group companies, affiliates and authorised agents or service providers, on a need-to-know basis and for legitimate business, compliance and contractual purposes. We may share personal data with:

  • Airpay Group companies, banking partners and payment networks;
  • technology, identity-verification and compliance service providers (as data processors under contract);
  • regulators, governmental and judicial bodies, and law-enforcement agencies, where required by law; and
  • auditors and professional advisers.

Airpay does not sell your personal data. We do not disclose specific information about customer accounts to non-affiliated third parties for their independent use, except where: (a) it is necessary to complete a transaction you initiate; (b) you request or authorise it; (c) it is required or directed by law; or (d) you have been informed of the possibility of such disclosure for marketing or similar purposes and given the opportunity to decline.

Cookie Policy

Cookies are small files stored on your device that help our websites operate efficiently, keep them secure, and provide a better experience. We also use similar technologies such as pixels, tags and local storage. We use the following categories of cookies:

  • Strictly necessary cookies – required for core website functionality, authentication and security. These cannot be switched off in our systems.
  • Performance cookies – help us understand website performance and how the site is used, so we can improve it.
  • Analytics cookies – help us measure usage and improve our products and services.
  • Preference cookies – remember your settings and preferences.
  • Advertising cookies – used, where legally permitted and with your consent, to deliver relevant content and measure campaigns.

Where required by applicable law, we place non-essential cookies only with your consent, obtained through our cookie banner. You can manage or withdraw your preferences at any time using the cookie management tool on our website or through your browser settings. Blocking some cookies may affect how the website functions. For details of the specific cookies used and their durations, see the cookie management tool. [Insert cookie inventory / link to cookie settings.]

Cross-Border Data Transfers

Because Airpay Group operates internationally, your personal data may be transferred to, and processed in, jurisdictions other than your own — including India, the UAE, Tanzania, Zambia and other countries where Airpay or its service providers operate — some of which may not offer an equivalent level of data protection. Where we transfer personal data across borders, we implement appropriate safeguards required by applicable law, such as standard contractual clauses, intra-group agreements, adequacy/whitelisting mechanisms or regulatory approvals, together with technical and organisational measures. By using our services and providing your information, you acknowledge such cross-border transfers, undertaken in accordance with applicable law.

Data Retention and Deletion

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected — including service fulfilment, legal and regulatory compliance, accounting or reporting requirements, fraud monitoring and dispute resolution. Retention periods vary according to the nature of the information and applicable law. Once data is no longer required, we securely delete or anonymise it in line with industry best practice. You may request deletion of your personal data, subject to any legal or contractual obligation that requires us to retain it for a longer period.

Security Measures

Airpay maintains administrative, technical and physical safeguards designed to protect personal data against unauthorised access, alteration, disclosure or destruction. These include encryption, access controls on a need-to-know basis, multi-factor authentication, firewalls and intrusion-detection tools, security monitoring, penetration testing, data-integrity validation, vendor due diligence, regular security audits and incident-response procedures. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Data Breach Notification

In the event of a personal-data breach, Airpay will notify affected individuals and the relevant supervisory authorities in accordance with applicable law and within the prescribed timelines. Notifications will, where required, describe the nature of the breach, the data involved, the likely consequences and the measures taken to address and mitigate it.

Use of AI and Automated Processing

Airpay may deploy artificial intelligence (AI), machine-learning models and automated processing to enhance customer experience, perform risk assessment, detect fraud, improve services and support credit evaluation. Such processing is carried out in a fair, transparent and lawful manner and will not result in unlawful discrimination or an adverse impact without appropriate safeguards. Where required by applicable law, we will obtain your explicit consent before such processing, and, where you have the right, you may request human review of, or object to, decisions based solely on automated processing that produce legal or similarly significant effects.

Governed Data-Processing Frameworks (MCP)

Airpay may use Model Control Policies (MCP) and governed data-processing frameworks to ensure responsible use, monitoring, validation and auditability of automated systems and data-processing activities, and to support compliance with regulatory standards, data-protection laws and internal risk-management policies.

Children’s Data

Our services are not directed at, or intended for, children who are not legally capable of entering into binding agreements under applicable law. Where we process the personal data of a child (in India, an individual under 18) or of a person under guardianship, we will do so only with verifiable consent of a parent or lawful guardian as required by applicable law, and we will not undertake tracking, behavioural monitoring or targeted advertising directed at children, or processing likely to cause a detrimental effect on a child’s well-being. If you believe we have collected a child’s data without appropriate consent, please contact our Data Protection Officer.

Your Rights
  • access the personal data we hold about you and obtain a summary of processing;
  • correct, complete or update inaccurate or incomplete data;
  • request erasure of your personal data (“right to be forgotten”), subject to legal retention obligations;
  • withdraw consent where processing is based on consent;
  • object to, or request restriction of, certain processing;
  • nominate an individual to exercise your rights in the event of death or incapacity (under the DPDP Act);
  • request data portability, where the applicable law provides for it; and
  • lodge a complaint through our grievance mechanism and, thereafter, with the competent supervisory authority.

To exercise any of these rights, contact our Data Protection Officer at dpo@airpay.in. We will respond within the timelines prescribed by applicable law and may need to verify your identity before acting on a request.

Fraud Prevention and Security Advisory

Fraud Alert – Airpay Group will never ask you to:

share an OTP (one-time passcode);
share your password, PIN or CVV;
share your full card number or internet-banking credentials; or
transfer funds to a personal account or install remote-access / screen-sharing apps.

If you receive such a request, it is a scam. Do not respond, and report it immediately to dpo@airpay.in, and to your bank. In India, you may also report to the National Cyber Crime Reporting Portal (cybercrime.gov.in) or call 1930.

Safe-usage guidelines: keep your credentials confidential; enable device security and app updates; review your account activity regularly; verify you are on an official Airpay domain before entering information; and report any unauthorised activity immediately.

Grievance Redressal Mechanism

Airpay Group is committed to the fair treatment of customers, merchants, and stakeholders and operates a transparent complaint-handling process. Grievances covered include payment disputes, service-related complaints, data privacy concerns, fraud-related complaints, account-related requests, and regulatory concerns.

When submitting a grievance, please include your full name, registered email address, mobile number, transaction reference (if applicable), and a detailed description of your complaint.

For complaints, concerns, or queries relating to personal data processing and privacy matters, you may contact the Data Protection Officer (DPO) at: dpo@airpay.in.

If you remain dissatisfied after exhausting our internal grievance process, you may approach the relevant regulatory or supervisory authority in your jurisdiction, subject to applicable law. Timelines will be adjusted where a shorter statutory period applies.

Links to Other Websites

Our websites may contain links to third-party websites. Once you link to another website, this Privacy Policy no longer applies, and Airpay is not responsible for the protection or further disclosure of information on those websites. Please review the privacy statements of any third-party websites you visit. Similarly, links to Airpay’s websites may appear on third-party websites; Airpay is not responsible for the content of, or acts or omissions committed on, such third-party websites.

Changes to This Policy

Airpay may amend this Privacy Policy from time to time. Amended versions will be published on the Airpay website with a revised “Last updated” date. We encourage you to review this Policy periodically. This Policy does not create any contractual or other legal rights or obligations beyond those provided under applicable law. Your continued use of our websites or services after any update constitutes acceptance of the revised Policy, to the extent permitted by law.

How to Contact Us

For any privacy question or request, contact us at: Data Protection Officer: dpo@airpay.co.in

This Privacy Policy should be read together with the Airpay Group Terms & Conditions. In case of any conflict between the English version and any translation, the English version shall prevail to the extent permitted by applicable law.